NURSING HOME COMPLIANCE: Stave Off Kickback Allegations By Covering These 4 Compliance Bases

Why This Topic Matters

Facilities that work with pharmacies, consultant pharmacists, and other outside providers can face fraud-and-abuse exposure if their contracts, pricing, or referral relationships are not structured carefully. Understanding the general compliance themes in this article can help readers evaluate whether their arrangements warrant closer review.

Article Sections

1. Background

   Introduces the broader compliance context and explains why arrangements with pharmacy-related providers may draw scrutiny. It also references federal enforcement activity and related allegations involving nursing homes.

2. Stay Problem-Free With These 4 Key Strategies

   Presents the main compliance themes discussed in the article and frames them as practical areas of review for nursing facilities. The section organizes the article’s guidance into several broad risk-management topics.

3. Specify the Duties of Consulting Pharmacists

   Discusses how facilities may structure consultant pharmacist relationships and mentions related OIG guidance and professional association commentary. The focus is on contract structure and regulatory oversight in long-term care settings.

4. Strive for Fair Market Value (FMV)

   Addresses pricing and valuation considerations in provider relationships. It emphasizes the importance of payment analysis and documentation in ancillary service arrangements.

5. Steer Clear of a "Swapping" Arrangement

   Describes the article’s discussion of suspect financial relationships between facilities and providers. It covers the general compliance concern associated with bundled services, pricing, and referral-related arrangements.

6. Pay Close Attention to FMV in Rental Agreements

   Covers leasing and space-rental scenarios involving potential referral sources. The section focuses on valuation and relationship considerations for property arrangements.